Dataram’s RoHS Compliance Management Statement
The European Union's directive 2002/95/EC (repealed effective January 3, 2013) and 2011/65/EU (Recast – transposed into law January 2, 2013), on the Restriction of Hazardous Substances (RoHS) restricts the use of certain hazardous substances commonly used in the manufacturing of electronic equipment. At Dataram, environmental soundness is a top priority of management and, where applicable, our manufacturing processes have been converted and materials procured were changed to achieve full compliance with this Directive. Note: Effective July 11, 2012 Dataram has purged all components which could have taken the 7CIII exemption which expires January 1, 2013. Therefore, we no longer take the exemption for modules that are Dataram manufactured after that date. Also of note, on 4 June 2015, the EU commission published a new Directive (EU) 2015/863 to amend and replace Annex II to EU RoHS 2 adding 4 phthalates onto the list of restricted substances.
As with any industry regulation, a first step to ensuring RoHS compliance is to understand the requirements, exemptions and the enforcement aspects of the legislation. RoHS requires manufacturers to know the compliance status for each part and material in their products. To demonstrate RoHS compliance for products on the market, companies must put proper controls in place and document their effectiveness. Reliable data management is key to proving compliance and demonstrating due diligence.
At Dataram, we use a central robust data management system to document our RoHS compliance. Our compliance information is incorporated in our product lifecycle management (PLM) system, which enables us to track compliance status throughout the development, testing and manufacturing stages of a product’s lifecycle.
Initial verification is conducted via a review of manufacturer’s compliance data followed by acquisition of the Material Declaration Sheet (MDS) in all cases where such information is available. After acceptance, the data are appended to our comprehensive PLM system.
Next, Dataram uses a “device qualification program” to track approved part numbers which are permitted for use. This method guards against the use of unauthorized devices after the primary product release. Once entered and approved, all parts and bills of material (BOM) are controlled via our engineering change notice (ECN) and corresponding documented approval process. This ensures compliance re-assessment for new revisions released into production.
Because Dataram tracks compliance against each internal part number, we can ensure that all parts are accounted for and approved for production. Our system also permits all users to track compliance in real-time from the same centralized system and allows for compliance roll-up through the assembly levels to the product level. This greatly improves efficiency, reduces errors, and enables us to develop efficient designs based on dynamic environmental compliance requirements. In addition, purchasing, manufacturing and quality organizations have access to the compliance data in order to implement compliance controls and record results (such as part screening and supplier reports) back into the compliance record.
As an ongoing confirmation tool, manufacturer part numbers are 100% verified against the Dataram PLM system at the time of receipt and then again at production inspection where a component ID is performed. Although this process requires constant monitoring and verification, it provides protection against possible device variations throughout the build and shipping processes.
